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Exemption 333 Request for UAS Operations utilizing

Aerial Release for Sterile Insect Technique (SIT)

Executive Summary

The M3 Consulting Group Sterile Insect technique (SIT) program is designed to offer 

researchers and public/private organizations a tool to enhance and/or supplement their existing 

SIT operations. Historical SIT operations have been commissioned using ground release and 

manned aviation release methods. The M3 Consulting Group SIT program is designed to 

dramatically increase the quality and effectiveness of aerial SIT release at a potentially 

discounted price point. This will be achieved by utilizing cost effective Unmanned Aircraft 

Systems (UAS) to release substrate at lower altitudes and airspeeds. 

Operational Summary

The M3 Consulting Group survey program will operate at low altitudes and slow airspeeds to 

perform SIT. Anticipated release height will be no more than 200 feet AGL and anticipated 

release speeds will be under 30 KTAS in airspeed. Operations will be restricted to class G 

airspace, occur only during daylight hours in VMC conditions, and use Class E visibility and 

weather standards as stated in 14 CFR 91.155.

Operations will require an observer working in tandem with the Pilot in Command (PIC) of the 

aircraft to comply with established See and Avoid methods regarding UAS operations in the 

NAS. Operations will be conducted within 1⁄2 NM laterally and below 200 feet AGL. Daily 

operations, multiple times per week, are anticipated.

Benefit to the Public

The M3 Consulting Group SIT Program will benefit the public by providing a safe, cost effective 

and rapid response means to provide release of SIT insects. An additional factor will be the 

elimination of risk to agricultural pilots as the aerial release of any substrate requires low and 

slow flight to ensure precision, which is extremely dangerous maneuver for conventional 

manned aircraft.

Aircraft Type

M3 Consulting Group intends to use multiple types of aircraft for its SIT release program. Flight 

vehicles will consist of a Vertical Take-Off and Land (VTOL) design and two fixed wing 

designs. These airframes will be operated in the same manner and will have similar Standard 

Operational Procedures (SOP) associated with them. 

M3 Consulting Group Hummingbird UAS (Manufactured by M3 Consulting Group)

See attached UAS Operating Manual
 

1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

M3 Consulting Group SOLO UAS (Manufactured by 3D Robotics)

See attached UAS Operating Manual

M3 Consulting Group Desert Cardinal UAS (Manufactured by M3 Consulting Group)

See attached UAS Operating Manual

Operational Risk Mitigation

M3 Consulting Group currently operates UAS utilizing SIT professionally under COA 2014-

WSA-225. The M3 Consulting Group SIT program will operate in exactly the same manner. 

Listed below is the order of operations that the M3 Consulting Group survey program will 

utilize:

1. PIC Completes Daily Flight Survey

2. PIC files any Notams or disclosures required for flight operations

3. PIC Completes Daily Risk assessment

4. PIC Completes Pre Flight Brief to crew

a. Assigns duties

b. Assigns duty locations

c. Gives description of operation to crew

i. Brief contents of COA

ii. Altitudes to be Flown

iii. Mission Overview

iv. Frequencies to be used

v. Flight time including reserve requirements

vi. Contingency procedures to include lost link, divert, and flight termination

vii. Hazards unique to the flight being flown

d. Programs relevant auto pilot information

i. GEO Fence coordinates

ii. Drop locations

iii. Lost communication landing location

5. Crew agrees to commence operations

6. Flight Operations Commence

7. Flight Operations End

8. PIC Revokes any Notams or disclosures required for flight operations

9. PIC logs relevant flight data into logbooks 

10. PIC releases crew
 

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Flight Survey

A survey of the flight operations area is an integral risk management strategy required for UAS 

flight operations. No flight operations shall be allowed without a PIC derived flight survey. The 

key elements to a proper flight survey are proximity to personnel and property, launch and 

recovery obstructions and operating areas, aircraft ditch locations, crew placement and safety 

concerns. 

Risk Assessment

A risk assessment will be developed daily and note specific weather and other area hazards. This 

worksheet calculates risk and derives a value of perceived risk. A high value risk assessment 

score will deny flight operations. 

Pre Flight Brief to Crew

This item is critical to a successful flight operation. The PIC weighs all the relevant factors and 

then briefs the crew for a successful mission. 

Maintenance

The maintenance program that M3 Consulting Group utilizes for all of its UAS include an annual 

inspection and a 100 hour inspection including the use of preflight and post flight inspections. 

The PIC is the final arbitrator as to the airworthiness of the aircraft. 

Each specific flight vehicle is issued an aircraft logbook that contains all maintenance actions. 

Training Program

M3 Consulting Group utilizes a training program for its UAS operators and observers. This 

program stresses 14 CFR part 91 requirements and UAV specific training. The maintenance 

program is an add-on to this training program. Each UAS has its own specific qualified 

maintainers. 

Communication Frequencies 

The Hummingbird UAS utilizes two forms of communication, the R/C transmitter and the

Ground Control Station (GCS) radio modem. The R/C transmitter uses a 2.4GHz band. The 

radio modem operates in the 900MHz band.

The Desert Cardinal UAS utilizes two forms of communication, the R/C transmitter and the GCS 

radio modem. The R/C transmitter uses a 2.4GHz band. The radio modem operates in the 

900MHz band.

The SOLO UAS utilizes the 2.4GHz band for all communication. 

The FCC classifies the 900 Mhz and the 2.4Ghz band as public use bands open for the public’s 

use. 
 

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Pilot and Observer Provisions

 Pilot Qualifications: M3 Consulting Group UAS pilots interacting with ATC shall have 

sufficient expertise to perform that task readily. Pilots must have an understanding of and 

comply with Federal Aviation Regulations applicable to the airspace where the UAS will 

operate. Pilots must have as a minimum a Private Pilot License. Pilots must have in their 

possession a current second class (or higher) airman medical certificate that has been issued 

under 14 CFR 67, Medical Standards and Certification. 14 CFR 91.17, Alcohol or Drugs,

applies to UAS pilots. Pilot will have satisfactorily completed the M3 Consulting Group 

UAS Training. Pilots will have completed a CRM training event reflected in FAA AC 

120.51E. 

 Observer Qualifications: Observers must have been provided with sufficient training to 

communicate clearly to the pilot any turning instructions required to stay clear of conflicting 

traffic. Observers will receive training on rules and responsibilities described in 14 CFR 

91.111, Operating Near Other Aircraft, 14 CFR 91.113, Right-of-Way Rules and 14 CFR 

91.155 Basic VFR weather minimums. Observers must have in their possession a current 

second class (or higher) airman medical certificate that has been issued under 14 CFR 67, 

Medical Standards and Certification. 14 CFR 91.17, Alcohol or Drugs, applies to UA 

observers. Observers will have in their possession a pair of binoculars. Observers will have 

satisfactorily completed the Desert Cardinal UAS observer training. Observers will have 

completed a CRM training event reflected in FAA AC 120.51E. 

Pilot-in-Command (PIC) – Visual Flight Rules:

 The PIC is the person directly responsible for the operation of the UAS. The responsibility 

and authority of the pilot in command as described by 14 CFR 91.3.

 The PIC must possess as a minimum a private pilot license and must keep their aeronautical 

knowledge up to date.

 The PIC does not necessarily have to be physically operating the radio transmitter but must 

be in a position to direct the flight and is responsible for all activities.

Pilot Currency – Visual Flight Rules:

 Pilots will not act as a PIC unless they have had three qualified proficiency events within the 

preceding 90 days. 

o The term “qualified proficiency event” is a UAS-specific term necessary due to the 

diversity of UAS types and control systems.

o A qualified proficiency event is an event requiring the pilot to exercise the training and 

skills unique to the UAS in which proficiency is maintained.

o Proficiency events can be actual UAS or RC flights 

o A pilot that loses currency can regain qualification by having a training event monitored 

by a qualified pilot.
 

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PIC Responsibilities:

 Pilots are responsible for a thorough preflight inspection of the UAS. Flight operations will 

not be undertaken unless the UAS is airworthy. The airworthiness provisions of 14 CFR 

91.7, Civil Aircraft Airworthiness apply. 

 One PIC must be designated at all times and is responsible for the safety of the UAS and 

persons and property along the UAS flight path. 

 The UAS pilot will be held accountable for controlling their aircraft to the same standards as 

the pilot of a manned aircraft. The provisions of 14 CFR 91.13, Careless and Reckless 

Operation, apply to UAS pilots.

 Pilot will check NOTAMs prior to flight to ensure that the flight NOTAM is posted and there 

are no conflicting NOTAMs for the flight area.

 Pilot will check the weather to ensure that there will be VFR conditions for the duration of 

the flight.

 Pilot will review aeronautical charts for the planned flight area and determine if there are any 

ATC agencies that will need to be contacted and have available radio frequencies and phone 

numbers, and check for airways and approach/departure corridors in the area of the planned 

flight.

 Pilot will perform a ground based flight survey, prior to flight.

 Pilot will have in their possession current sectionals and AFD for area of flight operations

Observer Responsibilities:

 Observer will ensure that adequate airspace de-confliction has been ensured and NOTAM’s 

are published for the day’s operation. 

 Observer will ensure that preflight briefings have been completed and crew is briefed. 

 Observer will ensure that while in flight the UAS stays clear of any conflicted air traffic. 

 Observer will ensure prior to UAS recovery that the area is clear of personnel and vehicles to 

maintain 500 feet of separation. 

Observer Currency:

 Observers shall have yearly periodic training on UAS Operations and Part 91 refresher.

PIC and Observer Duty Time Restrictions:

The PIC and Observer team of the UAS shall not accept a flight operation without adequate prior 

crew rest. This is described as 8 hours of continuous rest within the previous 24 hours. 

Additionally:

 Crew shall not accept scheduled flight operations that extend past 10 hours of on duty 

time from the start of operations. 

 Each Pilot and Observer will complete CRM training program based on FAA AC 

120.51E Crew Resource Management Training. 
 

1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

Maintainer Qualifications:

The M3 Consulting Group UAS program will ensure that extra training is provided for UAS 

personnel that are tasked to perform maintenance on the UAS. Each UAS crew member will 

have the ability to perform a pre and post flight inspection. It is in the best interest of the 

program to ensure that sufficiently trained personnel proceed past this inspection and perform 

further maintenance. These personnel shall have the additional title of UAS Maintainer. 

This training will be conducted during the UAS Operator Training Program. Selected personnel 

will be given additional hands on instruction and be given contact information for field 

maintenance problems. 

M3 Consulting Group

UAS Syllabus for Operator Training

Description

During this course each student will go through two phases of training. The first phase will be 

classroom instruction to give students the basic concepts of UAS operations. Students will learn: 

airspace, concept of flight, characteristics of the specific UAS, maintenance procedures and 

mission planning. This will ensure that the students understand the fundamentals of flight and 

the specific UAS. 

The second phase of the course will be conducted at a flight range. The students will receive the 

individual training required to safely operate the aircraft. M3CG anticipates that each aircraft 

operator will require a differing amount of instruction to operate safely. Ample time will be set 

aside to accomplish this task. 

Instructors

The M3 Consulting Group UAS Operator course will be taught by trained and certified M3 

Consulting Group UAS instructors. These instructors will possess UAS flight experience and 

have completed formal instructor training and certification. This formal training will be 

conducted and managed by the M3CG chief pilot. This ensures that the instruction program is 

up to date with the current operational procedures employed the aircraft manufacturer, M3CG.

The instructor will train students to a measurable standard while providing experience and 

knowledge from current field operations and standard operating procedures set forth by the chief 

pilot. This course of instruction is designed to update with the latest equipment incorporated into 

the aircraft as well as current tactics employed by M3CG.

Course Objectives

 Understand basic Aeronautics and concept of flight

 Understand Airspace and FAA regulations regarding operations in the NAS

 Introduce students to the specific UAS
 

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 Understand and conduct field maintenance for the UAS

 Operate safely the UAS 

 How to conduct currency flights for operators

Course Topics

 FAA and Airspace

 Concept of Flight

 System Overview

 System Assembly

 Mission Planning

 Ground Control Station (GCS) operation

 Take-off procedures

 Inflight procedures

 Landing procedures

 Maintenance procedures

 Currency flights

 Incident reporting

 Crew Resource Management

Evaluation

Each student will be evaluated during both phases of training. Each evaluation will be based on 

a pass or fail grade. At the completion of the live flight phase there will be an instructor 

evaluation for each student. The instructor will evaluate if the student can safely operate the 

specific UAS. This will be a pass/fail evaluation for each of the students. 

Training Day One Schedule

Administrative Class handouts and safety information.

FAA and Airspace Brief Give general instruction on FAA COA procedures and airspace.
 

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UAS info Demonstrate how the aircraft is assembled and operates on a 

static display.

Mission planning Demonstrate on a GCS how to set up a defined area to operate 

in and inform of safety features to keep aircraft in a defined 

area.

GCS Operation How the GCS communicates with the aircraft and 

troubleshooting information. Define how to load a mission.

Take-off procedures Give instruction on how to safely operate the aircraft during this 

phase of flight. Instruct emergency procedures. Define how to 

set up the area for a safe take-off.

In flight procedures Give instruction on how to safely operate the aircraft during this 

phase of flight. Instruct emergency procedures.

Landing procedures Give instruction on how to safely operate the aircraft during this 

phase of flight. Instruct emergency procedures. Define how to 

set up the area for a safe recovery. 

Maintenance procedures Instruct on how to repair minor damage and general 

maintenance of the aircraft. 

Instruct how to maintain 

currency

Inform students on how to maintain currency.

Incident reporting Inform student how to report mishaps and emergencies.

Crew Resource 

Management

Instruct principles of CRM.

End of phase one test Evaluate and give remedial training. 

Training Day Two Schedule and Phase exam

Assemble UAS Yes NO

Perform Preflight as operator 

and ground crew

Create Mission plan

Waypoints, Loiters, Fail safes

Launch UAS

Operate UAS inflight

Operate UAS in Altitude Mode

Operate UAS in Manual Mode
 

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Operator understands and is 

proficient at each section of the 

GCS

Conduct stall recovery

Repair and maintain UAS

Log all flights and maintenance 

items

Set up and conduct landing

Proficient at Manual landings

Perform post flight

Site break down

Students can conduct a proper 

currency flight

UAS Maintainers

The UAS program will ensure that extra training is provided for UAS personnel that are tasked 

to perform maintenance on the UAS. Each UAS crew member will have the ability to perform a 

pre and post flight inspection. It is in the best interest of the program to ensure that sufficiently 

trained personnel proceed past this inspection and perform further maintenance. These personnel 

shall have the additional title of UAS Maintainer. 

This training will be conducted during the UAS Operator Training Program. Selected personnel 

will be given additional hands on instruction and be given contact information for field 

maintenance problems. 

Safety

Safety is of paramount concern to M3 Consulting Group UAS operations and the SIT Program. 

Emergency and Normal procedures have been developed for each airframe that M3 Consulting 

Group utilizes. These same procedures have been utilized successfully on COA# 2014-WSA225. The UAS operations described for exemption 333 will not affect NAS safety as:

 The airframes have been engineered and tested for UAS operations.

 Operations will be conducted below 200 feet AGL.

 An observer will be present to comply with UAS See and Avoid precautions.

 All operations will be conducted utilizing line of sight and the UAS will venture no 

further than 1⁄2 NM from the Observer. 

 M3 Consulting Group currently operates UAS in the NAS utilizing COA# 2014-WSA225.

 The PIC and Observer will undergo company and UAS specific training.

 The UAS will not be operated within 500 feet of any person or vehicle during the inflight portion of the UAS operation. 
 

1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

 Operations will be conducted in class G airspace during daylight hours in VMC 

conditions using Class E visibility and weather standards stated in 14 CFR 91.155.

 The UAS will not weigh over 55LBS. 

 Operations will not occur over major cities – operations will be centered in rural areas.

 All UAS aircraft will be registered with the FAA Aircraft Registration Branch. 

Characteristics of Area of Operations

The M3 Consulting Group Survey Program is intended to operate in rural areas that are devoid of 

human population. Where Sterile Insect Technique (SIT) operations encounter personnel not 

associated with the UAS operation the UAS shall make every attempt to circumnavigate away 

from non-associated personnel and vehicles. 

River Operations

River Operations are the most probable area where non associated structures and personnel may 

be present. Proper flight survey and risk assessment usage will be paramount to reduce risk in 

this environment. 

Forrest Operations

Operations in forested environments are not expected to pose a hazard to non-associated 

personnel. The most probable safety event will be Controlled Flight Into Terrain (CFIT) with a 

tree or mountain. Crew communication and preflight planning will be paramount to avoid this 

hazard. 

Rangeland Operations

Operations in Rangeland environments are not expected to pose a hazard to non-associated 

personnel. The most probable safety event will be CFIT with a tree or mountain. Crew 

communication and preflight planning will be paramount to avoid this hazard. 

Proximity to Public Airports

The M3 Consulting Group SIT Program will not operate from public airports. The following 

guidelines will be followed. Operation will not commence within:

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an operational 

tower; or

 2 NM from an airport without a published instrument flight procedure or an operational 

tower; or

 2 NM from a heliport with a published instrument flight procedure

List of 14 CFR requested exemptions:

21 Subpart H – M3 Consulting Group requests relief from the requirement to receive and uphold 

an airworthiness certificate under FAA exemption 333. This will not compromise the safety of 
 

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the UAS operation as the aircraft will be operating under UAS manufacturer guidance and will 

be operating in rural areas. 

45.11 - M3 Consulting Group requests relief from the requirement to attach a fireproof 

identification plate to the aircraft as the UAS was not designed to accommodate the extra weight 

and/or physical space required for an identification plate. 

Part 61 – M3 Consulting Group requests relief from the requirements of 14 CFR part 61 which 

state that a commercial pilot’s license is required to conduct flight operations for profit or hire. 

91.103(b) (2) - M3 Consulting Group requests relief from 14 CFR Part 91.103 (b)(2) as the 

aircraft will not be operating from an airport environment. 

91.105 - M3 Consulting Group requests relief from 14 CFR Part 91.105 as no crew member will 

be onboard the aircraft. 

91.109 - M3 Consulting Group requests relief from 14 CFR Part 91.109 as no crew member may 

board the aircraft.

91.119 - M3 Consulting Group requests relief from 14 CFR Part 91.119 as the PIC of the aircraft 

will be remotely operating the aircraft and performing preflight checks within 500 feet of the 

aircraft. 

91.121 - M3 Consulting Group requests relief from 14 CFR Part 91 as there is no pressure 

sensitive or correcting altimeter located on the aircraft. 

91.151 - M3 Consulting Group requests relief from 14 CFR Part 91 as certain UAS vehicles may 

only have a maximum fuel capacity, whether electric or gasoline, for under 30 minutes of flight. 

The UAS in this circumstance is not capable of naturally complying with 91.151. 

91.203 - M3 Consulting Group requests relief from 14 CFR Part 91.203 as the aircraft operator 

requests to operate without the requirement of holding an airworthiness certificate for the UAS. 

91.205 - M3 Consulting Group requests relief from 14 CFR Part 91.205 as the UAS is designed 

to operate without the equipment specified in 91.205. 

91.207 - M3 Consulting Group requests relief from 14 CFR Part 91 as the aircraft is not designed 

for the payload capacity to lift or power an ELT as stated in 91.207. 

91.209 - M3 Consulting Group requests relief from 14 CFR Part 91.209 as the aircraft will be 

operated at a low level during daylight conditions. Lack of navigation lights will not affect the 

safety of flight operations as the aircraft is small and an observer will be providing the see and 

avoid aspect of flight separation. 

91.215 - M3 Consulting Group requests relief from 14 CFR Part 91.215 as the aircraft was not 

designed to accommodate nor carry a transponder. The aircraft will be operating below 200 feet 

AGL and will not be a hindrance to ATC nor other aircraft. 
 

1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

91.405 - M3 Consulting Group requests relief from 14 CFR Part 91.405 as the aircraft will have 

its own maintenance program as described by M3 Consulting Group. The PIC will be the final 

authority to the airworthiness of the aircraft. 

91.407 - M3 Consulting Group requests relief from 14 CFR Part 91.407 as the aircraft will have 

its own maintenance program as described by M3 Consulting Group. The PIC will be the final 

authority to the airworthiness of the aircraft. 

91.409 - M3 Consulting Group requests relief from 14 CFR Part 91.409 as the aircraft will have 

its own maintenance program as described by M3 Consulting Group. The PIC will be the final 

authority to the airworthiness of the aircraft. 

91.417 - M3 Consulting Group requests relief from 14 CFR Part 91.417 as the aircraft will have 

its own maintenance program as described by M3 Consulting Group. The PIC will be the final 

authority to the airworthiness of the aircraft. 

Abbreviations 

PIC Pilot in Command

SIT Sterile Insect Technique

AGL Above Ground Level

KTAS Knots True Airspeed

VMC Visual Meteorological Conditions

NM Nautical Mile 

VTOL Vertical Takeoff and Land

SOP Standard Operating Procedures

GCS Ground Control Station

UAS Unmanned Aircraft System

CFIT Controlled Flight into Terrain

Sincerely,

Dustin Krompetz

Chief of UAS Operations

M3 Consulting Group, LLC

dustin.krompetz@m3cg.us